ML24081A304
| ML24081A304 | |
| Person / Time | |
|---|---|
| Site: | 07103098 |
| Issue date: | 03/11/2024 |
| From: | Shaw D Orano TN Americas |
| To: | Boyle R Office of Nuclear Material Safety and Safeguards, US Dept of Transportation (DOT), Office of Hazardous Materials Safety |
| Shared Package | |
| ML23319A273 | List: |
| References | |
| A33010, L-2023-DOT-0002, E-63336 | |
| Download: ML24081A304 (9) | |
Text
Orano TN 7160 Riverwood Drive Suite 200 Columbia, MD 21046 USA Tel: 410-910-6900 Fax: 434-260-8480 March 11, 2024 E-63336 U.S. Department of Transportation Attn: Mr. Richard W. Boyle Pipeline & Hazardous Materials Safety Administration Radioactive Materials Branch 1200 New Jersey Avenue, S.E.
East Building, PHH-20 Washington, DC 20590
Subject:
Response to Request for Additional Information - Application for Revalidation of Competent Authority Certification J/2009/AF, Model No. GP-01
Reference:
[1] Letter dated May 24, 2023, from Norma Garcia Santos (U.S.
Nuclear Regulatory Commission) to Richard W. Boyle (U.S.
Department of Transportation), Subj: Request For Additional Information For Review Of The Certificate Of Compliance No.
3098, Model No. GP-01 (EPID L-2023-DOT-0002)
[2] TN-Americas letter E-62515 dated July 25, 2023, Subj:
Additional Information for Review of the Application for Revalidation of Competent Authority Certification J/2009/AF, GP
- 01.
[3] U.S. Nuclear Regulatory Commission, Conversation Record dated August 30, 2023 (Accession No. ML23300A074), including enclosures titled Staff's feedback on unacceptable responses of the RAIs related to the materials evaluation, Model No. GP-01 (Accession Nos. ML23300A076 and ML23300A078)
[4] Garcia-Sanchez, Norma (US NRC). Feedback--GP-01 RAI Unacceptable Responses. Received by Richard Boyle, (US DOT), September 7, 2023 (Accession No. ML23300A077)
[5] Garcia-Sanchez, Norma (US NRC). Feedback--GP-01 RAI Unacceptable Responses. Received by Richard Boyle, (US DOT), September 12, 2023 (Accession No. ML23300A075)
E-63336 U.S. DOT Page 2 of 2
Dear Mr. Boyle:
A request was submitted to revalidate J/2009/AF, which is a Type AF packaging meeting the applicable requirements for fissile material packages. The NRC issued a request for additional information (RAI) needed to complete their review [1], and TN Americas LLC (TN) responded to the RAI [2]. Preliminary responses to the structural and materials RAIs were provided for NRC review. The NRC review concluded that the RAI responses were unacceptable with comments provided [3, 4, and 5].
TN, on behalf of Orano Nuclear Packages and Services (NPS), requests that the DOT continue the review of the request for revalidation, taking into consideration the additional information provided for the Aging Management Program.
Should you have any questions or require additional information to support review of this application, please contact Peter Vescovi by telephone at 336-420-8325, or by e-mail at peter.vescovi@orano.group.
Sincerely, Don Shaw Licensing Manager TN Americas LLC cc:
Peter Vescovi, TN Americas, LLC Laurent Klein, Orano NPS Laurence Labbe, TN Americas, LLC
Enclosures:
- 1) GP-01 Package RAI-M-6 Supplemental Response SHAW Donis Digitally signed by SHAW Donis Date: 2024.03.11 14:15:37
-04'00'
to E-63336 GP-01 Package RAI-M-6 Supplemental Response
NRC Staff Comments to the GP-01 Package RAI-M-6 Response by NFI dated 10/31/2023:
- 1. The staff noted following discrepancies under Issue 4 - Thermal Stress Cycle, which need to be resolved:
- a. For evaluation of the thermal fatigue stress in the inner receptacle bottom plate, the applicant used fatigue design curve Figure 1-9.1M from the ASME BPV Section III, Mandatory Appendix 1, which is for the carbon steel material.
However, the material for the inner receptacle is stainless steel, for which Figure 1-9.2M should be used instead of Figure 1-9.1M.
Proposal answer of NFI We re-evaluated it by replacing the figure 1-9.1M with 1-9.2M. Please confirm the issue 4 in the attachment. Revisions are shown in red.
- b. At one location, the applicant identifies the estimated number of cycles for internal pressure during the service period to be 29, 200. In the subsequent paragraph, while comparing the allowable numbers of fatigue cycles from the ASME fatigue design curves, the estimated number of cycles is shown as 800 cycles. This discrepancy needs to be resolved.
Proposal answer of NFI This value is incorrect 800 cycles. The correct value is the 29,200 cycles. Please confirm the issue 4 in the attachment. Revisions are shown in red. Even if the number of cycles is 29,200, the number of this cycles are less than the number of allowable cycles ( more than 1.0 x 1011 cycles).
- 2. RAI-M-6
- a. The staff requested the applicant to provide a complete evaluation of fatigue for the reusable package components that considers the combined effects of all applicable types of accumulated stress cycles in components during normal service conditions.
The applicant evaluated the fatigue effects for the individual cycle types in the affected components, but did not provide cumulative results combining applicable cycle types for the affected package component. A method similar to that prescribed in ASME BPVC Section III, Division 1, NB-3222.4 (e) 5, Cumulative Damage, may be used to combine applicable cycle type effects in a component.
Proposal answer of NFI Stainless steel We consider inner receptacle pressurization cycles (issue (2)) and thermal stress cycles (issue (4)).
In issue (2), stress amplitude is 84.5 MPa, and the number of cycles of cyclic stress is 29,200. The allowable number of cycles is more than 1.0 x 1011 cycles. So, the usage factor (U) is U1=29,200/(1.0x 1011)=2.9x 10-7
In issue (4), stress amplitude is 57.5 MPa, and the number of cycles of cyclic stress is 29,200. The allowable number of cycles is more than 1.0 x 1011 cycles. So, the usage factor (U) is U2=29,200/(1.0x 1011)=2.9x10-7 The cumulative usage factor is U= U1+U2=2.9x10-7+2.9x10-7=5.8x10-7<1.0 The cumulative usage factor is not exceed 1.0, so the fatigue failure of the inner receptacle will not occur.
Rod bolts We consider lifting cycles (issue (1)), inner receptacle pressurization cycles (issue (2)),
and thermal stress cycles (issue (4)).
In issue (1), stress amplitude by lifting is 3916 psi (27.0 MPa), and the number of cycles of cyclic stress is 6400. The allowable number of cycles is more than 1.0 x 106 cycles.
So, the usage factor (U) is 60 MPa 90 MPa 1.0 x 1011 cycles
U1=6400/(1.0x 106)=6.4x 10-3 In issue (1), stress amplitude by tightening bolt is 50966 psi (351.4 MPa), and the number of cycles of cyclic stress is 800. The allowable number of cycles is more than 4.0 x 104 cycles. So, the usage factor (U) is U2=800/(4.0x 104)=0.02 In issue (2), stress amplitude is 2451 psi (16.9 MPa), and the number of cycles of cyclic stress is 29,200. The allowable number of cycles is more than 1.0 x 106 cycles. So, the usage factor (U) is U3=29200/(1.0x 106)=0.0292 In issue (4), stress amplitude is 1682 psi (11.6 MPa), and the number of cycles of cyclic stress is 29,200. The allowable number of cycles is more than 1.0 x 106 cycles. So, the usage factor (U) is U4=29200/(1.0x 106)=0.0292 The cumulative usage factor is U= U1+U2+U3+U4=6.4x 10-3+0.02+0.0292+0.0292=0.0848<1.0 The cumulative usage factor is not exceed 1.0, so the fatigue failure of the inner receptacle will not occur.
6.0x104psi 40,000 cycles 1.0x106 cycles 1.0x104psi
- b. The applicant provided the following calculation:
Fz should be 33,922 per Sec A.4.4.5, page II-A-23. Although the resulting value appears to be correct, so it appears to be a typo error. Please fix a typo error in a submittal.
Proposal answer of NFI Revisions are shown in red.
- c.
"0.1 x " is missing, but resulting value appears to be correct, so it is a Typo error.
Proposal answer of NFI Revisions are shown in red.
- 3. There are some instances in the submittal in which the exponents have to be fixed. For example:
In the response to RAI-M-6, the applicant mentioned 3.0 x 104 psi. The response should be revised 3.0 x 104 psi. The same applies to other instances in which the exponents are not showing correctly.
Proposal answer of NFI Revisions are shown in red.
- 4. It will be beneficial to mark in the graph the values used for the calculations (see figure below).
- 5. The Figure 1-9.1 below is for the carbon, low alloy steel, which is not correct for Stainless Steel Fatigue Curve. The Figure 1-9.2M should be used instead for Stainless steel. The RAI supplement needs to be revised.
Proposal answer of NFI We re-evaluated it by replacing the figure 1-9.1M with 1-9.2M. Please confirm the issue 4 in the attachment. Revisions are shown in red.